News & Analysis as of October 12, 2024

Proposed Regulation

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations for Some US Taxpayers

Katten Muchin Rosenman LLP on 5/15/2024

It is quite common for high-net-worth individuals to have income streams from multiple countries. For example, an individual may have an ownership interest in a foreign (i.e., non-U.S.) company, be a beneficiary of a foreign...more

How Will the New Crypto Tax Proposal Potentially Affect Your Current Digital Strategy?

Allen Barron, Inc. on 3/19/2024

How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more

Digital Assets Reporting Requirements Under Section 6050I

Falcon Rappaport & Berkman LLP on 1/22/2024

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Gray Reed on 8/7/2023

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time. On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

Playing the Waiting Game on Crypto Tax Reporting

Cadwalader, Wickersham & Taft LLP on 6/28/2023

As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more

Proposed Treasury Regulations Would Disallow Technique to Reduce Subpart F and GILTI Inclusions

Cadwalader, Wickersham & Taft LLP on 12/20/2022

On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on 1/26/2022

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

[Podcast] Statues, Texas Apportionment (Sirius XM), and Maryland Digital Ad Tax Regs

BakerHostetler on 10/13/2021

Matt Hunsaker breaks down the latest state tax news including a discussion of tax arguments in a controversial civil war era statue removal case, the Texas Supreme Court's decision to hear Sirius XM's apportionment case, and...more

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on 12/8/2020

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

McDermott Will & Emery on 9/3/2020

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Emery on 12/18/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Weekly IRS Roundup November 18 – 22, 2019

McDermott Will & Emery on 11/27/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on 10/9/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Weekly IRS Roundup September 9 – 13, 2019

McDermott Will & Emery on 9/17/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more

Weekly IRS Roundup September 2 – 6, 2019

McDermott Will & Emery on 9/9/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019. September 3, 2019: The IRS issued a notice in which it released the...more

Weekly IRS Roundup July 1 – 5, 2019

McDermott Will & Emery on 7/8/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 1 – 5, 2019. July 2, 2019: The IRS issued a Chief Counsel Notice wherein the Chief...more

Weekly IRS Roundup June 3 – 7, 2019

McDermott Will & Emery on 6/10/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

Weekly IRS Roundup February 25 – March 1, 2019

McDermott Will & Emery on 3/4/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more

Colombia Propone Cambios a las Regulaciones Tributarias - Una Mirada a los Principales Cambios Propuestos por la Ley de...

Holland & Knight LLP on 11/5/2018

En términos generales, los cambios impositivos propuestos más grandes de Colombia tendrían un impacto en el Impuesto sobre las ventas (IVA), la creación de un impuesto unificado denominado SIMPLE, la emisión del impuesto a la...more

The New Section 199A 20% Profit Deduction for Pass-Through Businesses: A Case Study: Court Reporters

Burr & Forman on 10/23/2018

Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more

Client Alert: Purchases of Partnership and LLC Interests Adversely Affected by Newly-Proposed Regulations Under Code Section 199A

Neal, Gerber & Eisenberg LLP on 10/9/2018

Historically, we have advised clients that it is no less advantageous, from a federal income tax perspective, to acquire a partnership interest (including a membership interest in an LLC taxed as a partnership) than it would...more

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